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Why do European CAAs not notify pilots of relevant matters and instead just wait for them to fly illegally?

chflyer wrote:

I prefer the US system where the FAA generally keeps information on a need to know basis, a pilot certificate never expires, and meeting currency dates is the responsibility of the pilot.

Not that different here anymore as well… your FCL license never expires but you need to take care of currency and your ratings. And yea, medical is purely your own business to think of.

However, I think what Peter meant was the story from before EASA FCL with the transition from national to JAA licenses, when the old ones actually became invalid. Same happened again with JAA to EASA FCL. Even though, JAA licenses never really became invalid but had to be converted. Our FOCA was quite pro active at the time if I am not mistaken (national to JAA definitly) sending out letters telling people to change.

chflyer wrote:

This is part of the paternalistic expectations many people in Europe have of their government.

I think also the FAA is quite pro active in such extreme cases and so they should be. IMHO, if any government does change something really fundamental it is at least in part their duty to adequately inform those concerned. People generally are quite oblivious to bureaucracy. Some folks here will find themselves without a valid drivers license in a few months, despite being told over and over again to change it… and a 10 year space of time to do it…

LSZH(work) LSZF (GA base), Switzerland

Mooney_Driver wrote:

Not that different here anymore as well… your FCL license never expires but you need to take care of currency and your ratings.

Perhaps the actual FCL licence, as in the CAA records, never expires. But the physical licence does. The validity of the class and type ratings are printed on it, and a revalidation results in a new physical licence being issued. But it is better than previously. My CH ICAO licence even had the medical expiry information on it, and that is now a separate document. That licence expired around 2001 before JAR, and the Swiss FOCA never sent me any reminder. Of course, they might have taken a different approach with the migration from JAR to EASA FCL. Today they don’t send medical expiry reminders. I just converted my ICAO licence to EASA JCL, so I don’t yet know if they send reminders about rating expiry.

With the US, the physical certificate has no expiry date printed on it, and any required currency, checks, or revalidations are recorded separately from the certificate, normally in the pilot’s logbook but any piece of paper with the required information is sufficient.

In practical terms, the major difference is the ease of verification when an expiry date is on a document. A glance at an EASA FCL licence tells if the ratings for the current operation are valid or not. With the US, a log book review may well be needed which means retrieving it from its storage location, wherever that might be….. could be halfway around the world.

LSZK, Switzerland

chflyer wrote:

Perhaps the actual FCL licence, as in the CAA records, never expires. But the physical licence does. The validity of the class and type ratings are printed on it, and a revalidation results in a new physical licence being issued.

The competent authority can allow the examiner to endorse the physical license with the revalidation. (ARA.FCL.215) E.g. my physical Swedish FCL license can never expire – the examiner simply writes the new expiry date of the class (and IR) ratings on the license itself. (Well, I guess that eventually there will be no space left and then I have to get a new physical license, but at least there’s no specific time period for that.)

ESKC (Uppsala/Sundbro), Sweden

chflyer wrote:

In practical terms, the major difference is the ease of verification when an expiry date is on a document.

I think the major difference is that after FAA pilot has achieved a given rating (for example PPSEL or multi-engine or IFR) he cannot be accused of flying without that rating, because it cannot expire, only of neglecting to get e.g. a periodic flight review with an unaffiliated, individual instructor or of not being IFR current through rolling currency. That is a relatively minor transgression and some US insurance policies grant waivers for overdue flight reviews making this a relatively limited issue when flying under FAA regs. The FAA system is not this way by chance, or through naivete, it is by design: the issue is not considered important enough to justify more oversight. Until some time in the ‘70s no periodic flight reviews were required either, as well as no expiration of pilot certificate or ratings. Also, the FAA has no records on anything related to an individual’s private pilot currency, as well as obviously having no records on rating expiration for ratings that can’t expire. The only one they think is important enough to track is Medical/Basic Med status, not including Sport Pilot operations that don’t require any FAA medical certification, and if the pilot is operating under an FAA Medical he needs to have a copy on hand. I think most pilots can keep track of that successfully without the FAA sending them notification!

By my observation the only time an FAA pilot would be questioned on his currency is after an accident, at which point there is plenty of time for him to retrieve his personally kept record. And he will never be questioned about ratings because once they’re on the FAA record and printed on his plastic credit card sized pilot certificate they can’t disappear.

This is not shades of grey, it is a completely different regulatory philosophy that has proven effective without imposing undue burden.

Last Edited by Silvaire at 07 Jun 20:19

Very well put!

Administrator
Shoreham EGKA, United Kingdom

Silvaire wrote:

This is not shades of grey, it is a completely different regulatory philosophy that has proven effective without imposing undue burden.

Agreed. The loss of ratings is a major problem here.

The question however was, how would the FAA communicate regulatory changes to licence holders. It appears that some CAA’s in Europe lack in this respect.

LSZH(work) LSZF (GA base), Switzerland

I am sure all European CAAs have names and addresses of all the pilots they “own”, so the differences will be in what occassions (revalidations etc) involve returning paperwork to the CAA.

In the UK, most things do return paper to the CAA. Actually I can’t think of one that doesn’t. And this is another screwed-up area: if a rating has expired by more than 3 years, and you have to send your license back to the CAA, the CAA will remove that rating from the license, and then it cannot be revalidated with a freelance examiner anymore.

So they have a lot of control over you – yet they still choose to not notify you of important stuff.

Administrator
Shoreham EGKA, United Kingdom

@Mooney_Driver, FAA doesn’t have a lot of regulatory change so your question is not easily answerable.

Endless regulatory churn is a problem wider than just pilot licensing. ‘Managing change’ and creating issues are ways people in organizations make jobs for themselves. The creation of unnecessary change is a problem within any organization that has too many people or too many of the wrong kind of people. Meanwhile anybody doing business with the organization pays a price in time and effort.

I think the Issue is not timely and accurate notification of aimless change to individual customers, that’s unlikely to happen anywhere because it’s impractical and expensive. Instead the core issue is that neither the creation of stability nor reducing the burden of unnecessary regulatory process are goals. The common factor between those factors is that they both create employment within a self serving organization, the existence of which is the problem.

Last Edited by Silvaire at 08 Jun 12:03

There is a lack of feedback from the UK CAA. When Language Proficiency started, there was an added page on the SEP revalidation form for language proficiency. I posted it with LP6.
I was told in a telephone conversation with the CAA that the extra page had not been scanned in. For years I was illegally speaking English. I also found my SEP revalidation had not been recorded for several years. No problem if ramp checked, but if I was lost at sea the AAIB would believe I hadn’t had my biennial flights
My first attempt to sort it was misunderstood as a licence application, and returned when I didn’t submit other evidence. Second attempt succeeded.
(Fortunately the Examiner was one of the Syndicate of 6 owning our Jodel.)

Maoraigh
EGPE, United Kingdom

Silvaire wrote:

I think the Issue is not timely and accurate notification of aimless change to individual customers, that’s unlikely to happen anywhere because it’s impractical and expensive.

Well, this is what this thread is about.

It works fairly well about AD’s for instance. Myself, i find the communication of our on FOCA mostly adequate and timely. What I am seeing from the FAA is that they are also communicating quite openly.

Silvaire wrote:

Instead the core issue is that neither the creation of stability nor reducing the burden of unnecessary regulatory process are goals. The common factor between those factors is that they both create employment within a self serving organization, the existence of which is the problem.

So the theory you proclaim is that you would be better off without any regulatory body? that certainly is an utopia which many live, but does it really work?

LSZH(work) LSZF (GA base), Switzerland
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